HUD Case #

[Marcia Langley]

OSU,

An FHA approved lender is not likely to do that but I can see lots of potential for an intermediary like a mortgage broker to claim the appraiser never delivered the report.

The only way an appraiser could track that is to check with any of the lenders or the HOC and ask if your appraisal was logged in. If not, report it to the HOC.

This new business of shifty subprime MBs getting involved in FHA work has caused lots of problems to surface that were not really a problem before.

 

[OSU Beavers]

Couch, Marcia,

This is happening every day. Just last week I got a call from a MB who used a Skippy first to hit the number on an FHA report. The underwriter called BS on the report since the three sales used did not "look" like the subject and asked for interior photos on the subject plus a fourth comp of the same style & age. Skippy wanted to charge an additional 50% of his fee to go back and get those photos (who does not get interior photos on every inspection these days!?!) so the MB went looking for a new appraiser to assign the case number to.

Reassigning the case number to another appraiser takes 30 seconds on the FHA Connections site and seems to have no consequences as long as the first completed appraisal was never logged in. How many of you have gotten case number printouts with another appraisers name on it. I did and called the lender. "Oh no problem that's just a name we put in to get the case number then change it once we find an appraiser" then a minute later the new print out comes over the fax with my name on it this time.

HOC does not care, they are the new sub-prime, the backdoor way of helping stop the foreclosure waves from crashing the whole industry. They don't want to rock the boat.

 

[Marcia Langley]

OSU,

I agree this is a huge problem. In the case you describe the UW has rejected the report for being unethical. I'm not sure what the bank's FHA rule is for that. It may be that they don't have to log in appraisals that are unethical.

But that's just one case. Skippy is not likely to report the failure to log the appraisal in. I doubt much can be done about that.

It's sad, but it seems it is up to each appraiser to make sure their own appraisal was logged in. Usually this question will come up when a new lender tries to order again from the same appraiser.

 

[Oh No Not Him]

I have a slightly different question on same topic....buyer is merely switching to a different lender...they dont under stand that i cant just re-assign the report..i wish FHA had us put "any approved FHA lender" like VA does...I hate dealing with the BS that arises from switching lenders...to be blunt, I dont do anything for free....how do most of you handle this..same buyer, same FHA case #.."?

 

[OSU Beavers]

See this is why we need an FHA Assignment Rules sticky. From what I gathered there can be no retypes to put the second lenders name on the report. No new appraisal for six months. Now the new from sub-prime MB tards don't know or care about this so every phone call is a fight ending with the appraiser saying "You are not my client, go away" and then the borrower calling the state complaining that the appraiser is holding up their loan.

Marcia, the underwriter (not sure if it was the MBs or the registered lenders) was only asking for additional information not rejecting the report. Skippy refused to provided it without an addition 50% of his fee so that is when the MB went looking for someone else.

 

[Couch Potato]

Couch, Marcia,

This is happening every day. Just last week I got a call from a MB who used a Skippy first to hit the number on an FHA report. The underwriter called BS on the report since the three sales used did not "look" like the subject and asked for interior photos on the subject plus a fourth comp of the same style & age. Skippy wanted to charge an additional 50% of his fee to go back and get those photos (who does not get interior photos on every inspection these days!?!) so the MB went looking for a new appraiser to assign the case number to.

Reassigning the case number to another appraiser takes 30 seconds on the FHA Connections site and seems to have no consequences as long as the first completed appraisal was never logged in. How many of you have gotten case number printouts with another appraisers name on it. I did and called the lender. "Oh no problem that's just a name we put in to get the case number then change it once we find an appraiser" then a minute later the new print out comes over the fax with my name on it this time.

HOC does not care, they are the new sub-prime, the backdoor way of helping stop the foreclosure waves from crashing the whole industry. They don't want to rock the boat.

They do care; however, when the lender can show the appraisal is BS they can get it reassigned. There are consequences and the skippy to whom you refer will likely hear from HUD about the issue of poor performance. If it turns out the appraisal was good, the lender will face consequences.

HUD is a government agency. They don't move quickly, but they do get there eventually. When they do get there, they come down hard on mortgage brokers not playing by the rules. Like appraisers, mortgage brokers are powerless individuals and get no special treatment from HUD.

 

[David S. Roberson]

Yes, it's very easy to get a case reassigned. Sellers here choose the appraiser, and have the lender reassign the case to their appraiser.

 

[SANDY]

Greg Boyd:

I guess my thread about this whole issue way back when was not so naive after all!

 

[Marcia Langley]

In general, the HOC is probably willing to have the case reassigned to a different appraiser as long as the appraisal has not been logged into the FHA system. They probably require the FHA approved lender to give an acceptable reason for doing so. Acceptable reasons are probably very easy to come up with and I wouldn't imagine there would be much of a deterrent for the lender. I imagine they have a list of acceptable reasons and all they have to do is pick one.

This is not something appraisers can do anything about. I suspect that FHA is not very interested ramping up their staff levels to police the suspicious activities of MB originated appraisals. It is the responsibility of the lenders to do so.

However, if your own appraisal fails to get logged, it is appropriate for you to report it. And if you have evidence of some other bad actions, report that, too.

Really, the only avenue appraisers have is to report bad actions. We do have the opportunity to at least monitor and report activity related to our own appraisals.


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As a separate subject ...


I'm curious as to what FHA guidelines are imposed on the lenders for the handling of bad appraisals. Obviously FHA approved lenders have the right to reject bad appraisals. I'm curious if FHA rules require that such bad FHA case number assigned rejected appraisals be delivered with a complaint to the HOC or otherwise delivered to state authorities.

This, of course, gets into that problematic area of production staff (bank employees and MBs) being able to direct the appraisal. As long as production staff is allowed to direct the appraisal, abuses will occur. I think it may be a little unreasonable to expect FHA to singlehandedly fix this problem, even for just their own loan packages.

The resentment among appraisers arises when a system is touted as having some control over certain bad actions when, in truth, it doesn't.

 

[Michael Tipton]

I have a slightly different question on same topic....buyer is merely switching to a different lender...they dont under stand that i cant just re-assign the report..i wish FHA had us put "any approved FHA lender" like VA does...I hate dealing with the BS that arises from switching lenders...to be blunt, I dont do anything for free....how do most of you handle this..same buyer, same FHA case #.."?

The different (new) lender's requirements are indicated in 4-2 Transfers of Case Numbers Between Lenders. Refer the new lender to Appendix D page D-11 items 21, 22 and 23. Item 22 states the appraiser is subject to the provisions of USPAP, therefore, "re-assigns" are addressed by USPAP.

CHAPTER 4 CANCELLING CASES AND TRANSFERRING CASE NUMBERS​

4-1 CANCELLING CASES. The lender must notify the appropriate HOC
via FHA Connection, or its functional equivalent, to close outstanding files and cancel the FHA case number if the origination and closing of a loan will not be completed or if FHA mortgage insurance endorsement will not be sought.​

4-2 TRANSFERS OF CASE NUMBERS BETWEEN LENDERS.​

A. New Lender. Lenders are expected to cooperate in the transfer of case numbers. At the request of a borrower, the case number is to be assigned to the new lender using the Case Transfer function in FHA Connection. The transferring lender is not entitled to a fee for the transfer of a streamline refinance case number, regardless of the stage of processing the loan is in. The transferring lender may be entitled to any lock-in fee collected from the borrower at the time of application. The transferring lender is required to provide the new lender with the appraisal but is not required to provide any processing documents. If processing documents are transferred, the fee for providing these documents is to be negotiated between the lenders. No separate charge to the borrower is authorized for this transfer.​

B. New Borrower Using an Existing Appraisal. If the transfer is made for a new borrower to use an existing appraisal, the new lender is to collect an appraisal fee from the new borrower. The appraisal fee is sent to the original lender who, in turn, is to refund the fee to the original borrower.​

C. Rejected Loan. If the transfer involves a rejected loan, the original lender must complete the Mortgage Credit Reject function in FHA Connection prior to transferring the loan.​

D. Master Appraisal Report (MAR), Form HUD-91322.i. In the case of a MAR, the transferring lender is only entitled to a pro-rata share of the cost of the MAR. For example, if the MAR is for 100 units and cost $10,000, the new lender would pay the transferring lender $100. While a lender may have provided resources to obtain the MAR in anticipation of capturing most -if not all -of the individual mortgage loans, it may not deny an appraisal assignment request to a borrower who wishes to
use an alternative mortgage lender.​